ML20128D463
| ML20128D463 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/15/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0124K, 124K, NUDOCS 8505290081 | |
| Download: ML20128D463 (5) | |
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Commonwealth Edison one First National Plazi, Chicego, lihnois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 May 15, 1985 Mr. James G. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Il 60137
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Subject:
Braidwood Station Units 1 and 2 Response to Inspection Reports Nos.
50-456/85-008 and 50-457/85-008 NRC Docket Nos. 50-456 Reference (a):
J. J. Harrison letter to C. Reed dated April 18, 1985
Dear Mr. Keppler:
This letter is in response to the inspection conducted by Messrs. D. L. Williams, A. Dunlop, M. J. Farber and M. A. Ring on February 14 through March 27, 1985 of activities at Braidwood Station.
Reference.(a) indicated that certain activities appeared to be in noncompliance with NRC requirements.
The Commonwealth Edison Company response to the Notice of Violation is provided in the enclosure.
If you have any further questions on this matter, please direct them to this office.
Very truly yours, h
eg.
W' uD. L. Furrar Director of Nuclear Licensing
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NRC Resident Inspector Braidwood Enclosure 0124K 52%$8k$5 [
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MAY 2 01985 A ~b 0 /
jf c.,7 ENCLOSURE Response to a
Inspection Report-'456/85-008 and 457/85-008
- Item 456/85-008-10a, 456/85-008-10b and-456/85-008-10c
- Item of' Noncompliance As a' result'of the' inspection conducted on February 14-
- through '. Ma rch. 27, 1985, and in accordance~with the General Policy land procedures for-NRC Enforcement. Actions, (10 CFR Part 2, Appendix
-C),1theLfollowing violation was identified:
!10 CFR:50, Appendix--B, Criterion XIII states, in part, that
" Measures shall'be established to control the. handling, storage,ishipping,,, cleaning and preservation'of material
~ and, equipment...to' prevent damage or. deterioration."
The m
Commonwealth Edison Company QualityzAssurance Program-contains in Quality Requirement Q.R. 2.0 a commitment to
'the-regulatory positions of Regulatory Guide 1.37, Revision 0, Regulatory Guide ~1.38, Revision 2, and Regulatory Guiden 11.39,, Revision 2.
. Regulatory: Guide 1.37, Revision 0 endorses _the-requirements of-ANSI N45.2.1-1973, " Cleaning of Fluid Systems'and Associated Components During' Construction Phase of a Nuclear Power Plant."
Section 6, '? Maintenance of
-Installation Cleanliness", states, in part, "If access to a sealed system-is required, precautions shall be taken to prevent introduction of-contaminants.
Prior to opening the seals, the'immediate surroundings should be cleaned to remove solid contaminants.which might be introduced _in the system.
Personnel entering the system ~should wear clean outer clothing and shoeLcovers. _ WhenLthe necessary work-is completed, the interior surface shall be locally cleaned to-its original condition and'the system should~be re-sealed."
Regulatory Guide 1.38, Revision 2 endorses-the requirements of ANSI N45.2.2-1972, " Packaging,. Shipping, Receiving,
,7 Storage and Handling of Items for Nuclear Power Plants 0
During the Construction Phase."
Section '6.5 of ANSI N45.2.2 states, in part, that, " Items released from' storage and placed in their final locations within the power plant, shall be... cared for in accordance with the' requirements of Section 6 of this Standard."
Section 6 of ANSI N45.2.2 states in part that, "(6.1.1) Level and methods o f storage necessary are defined to minimize the possibility of damage or lowering quality due to corrosion, contamination,-
deterioration, or physical damage.
-(6.2.2) Cleanliness and good housekeeping practices shall be enforced at all_ times in the-storage areas.
(6.4.2) Items..".shall have all covers, caps, plugs.'or other closures intact... covers removed'for internal-access at any time for any reason shall be:immediately(replaced and resealed'after completion lof'the purpose for removal."
3 Appendix
' Regulatory Guide l'.39, Revision 2 endorses the requirements o f ANSI N45.2-3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plants".
Section 3.2.1 states, in part, " Garbage, trash,_ scrap, littet and other excess material shall be collected, removed from the job site, or disposed of.in accordance with specified requirements or planned practices.
Such excess material shall not be allowed to accumulate and create conditions that will adversely affect quality."
Contrary to the above:
- a. Shoe covers were not provided or worn by personnel. entering
~the recir,culation sump area during BWPT EF-ll and some debris was noted in the sump water during the preoperational test.
b.H0n March 15 and 21, 1985, the permanent spool pieces for Residual Heat Removal Suction lines and Containment Spray Pump Suction lines were found with inadequate or non-existent coverings for protection from damage or
. deterioration of these components.
- c. On March 15 and 21, 1985, during tours of the 1A positive displacement-charging pump' room the following was observed; empty cans in the room cooler, plastic sheeting strewn about the area, partially eaten food items, accumulation of flammable material and a layer of dust on all equipment in the room.
Response - Part a The cleanliness program for the EF-ll test was reviewed with the NRC prior to its implementation.
Commonwealth Edison Company agrees that shoe covers were neither required by the program established nor provided or worn by personnel entering the recirculation sump area during the EF-ll test.
Further, we agree that Commonwealth Edison is ultimately responsible for setting requirements and maintaining cleanliness during testing.
Prior.to commencing the test the sump was hand wiped to remove any foreign material.
Immediately prior to the test the sump area'was again examined by EF-ll testers and the shift personnel.
Some additional debris was found and removed at that time.
The Inspector's observation of debris "primarily paper" was also observed by the EF-11 testers and was believed to be purge dan material.
Corrective Action Taken-and Results' Achieved Upon the expression of-concern by the NRC for lack of shoe covers, Commonwealth. Edison took immediate action to-place shoe covers 11n the area and-to-post the area to require-shoe covers-to be-worn in the sump area for the remaining portion of'the EF-ll Test.
-Corrective Action:Taken to-Avoid Further Noncompliance
' Commonwealth Edison Company will conduct training with all
-Start-up' testing personnel.
.This training will apprise the start-up test engineers of.this incident and:of the facts that the-Lestablishment of specific requirements for cleanliness requires follow-up'and that any~ established cleanliness requirements should be' discussed.during the test briefings.
This training will also
' include a discussion,of general _ housekeeping requirements during
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testing.and specific training on the Project-Construction Department procedure:for housekeeping PCD-05, " Project Housekeeping" Revision No. 2.
Date of Full -Compliance-LTraining will be completed by July 1, 1985.
Response --Part b
' Commonwealth Edison recognizes the need to maintain piping.
cleanliness during installation. ife acknowledge the example' cited
'by the Inspector,of tape-coverings not intact.
- However, Commonwealth Edison believes that tape, when intact, is an adequate protective covering method.
Corrective Action Taken and Results Achieved The referenced spool piece covers were inspected.
Phillips
_ Getschow Co. has been instructed to verify that spool piece covers are. intact or to repair or replace them as necessary.
Corrective Action Taken to Avoid Further Noncompliance Cleanliness of piping at the time of installation is-verified by Phillips.Getschow Co.
in accordance with procedures QCP-B28'and PGCP-15.
Phillips Getschow management will issue a memo
.to applicable foreman reminding them of requirements necessary to maintain cleanliness of piping during installation.
Date of Full Compliance Corrective actions will be complete by June 10, 1985.
Response - Part c
-Commonwealth' Edison agrees there was an accumulation of debris in the'lA positive displacement charging pump room.
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Corrective-Action Taken and Results Achieved Commonwealth Edison instructed the contractor responsible for cleanliness control'in this area to clean the area.
This area was cleaned.
Corrective Action Taken to Avoid Further Noncompliance A letter was issued to G. K. Newberg on May 7, 1985, discussing this discrepancy and directing that appropriate field personnel be informed of this problem. -In addition, the provisions of Project Procedure _PCD-05 will continue to be implemented by Commonwealth Edison and site contractors.
Date of Full Compliance All corrective actions are completed.
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